MSGI Security Solutions, Inc. v. Hyundai Syscomm Corporation et al

Filing 119

STIPULATION AND ORDER RE 118 TO EXTEND TIME TO COMPLETE EARLY NEUTRAL EVALUATION. Signed by Judge Richard Seeborg on 3/7/11. (cl, COURT STAFF) (Filed on 3/7/2011)

MSGI Security Solutions, Inc. v. Hyundai Syscomm Corporation et al

Doc. 119

*E-Filed 3/7/11* 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO ALL PARTIES AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD: This Stipulation is made pursuant to ADR L.R. 5-5 and is made between Plaintiff MSGI Security Solutions, Inc. (hereinafter "MSGI") and Defendants Hyundai Syscomm Corporation, Hyundai Syscomm Inc., Apro Media Corporation, Hirsch Group LLLP, Hirsch Capital Corporation, Hyundai RFMON Corporation, Samuel Lee, Jack Choe, Benjamin Byun, Wallace Benjamin Garst, Jr., and David Choe (collectively known as "Defendants"), by and through their respective counsel. The parties herein agree and stipulate as follows: 1. On or about July 21, 2009, this action was filed with the Northern District of AND RELATED COUNTERCLAIM Plaintiff; v. HYUNDAI SYSCOMM CORPORATION, et al., Defendants. MSGI SECURITY SOLUTIONS, INC., a New York Corporation, Case No. C09-03330-RS STIPULATION TO EXTEND TIME TO COMPLETE EARLY NEUTRAL EVALUATION AND [PROPOSED] ORDER Attorneys for Plaintiff MSGI Security Solutions, Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA WILLIAM J. GOINES (SBN: 61290) ALICE CHU (SBN: 264990) GREENBERG TRAURIG, LLP 1900 University Avenue, Fifth Floor East Palo Alto, California 94303 Telephone: [phone] Facsimile: [phone] Email: goinesw@gtlaw.; [e-mail]

California, San Jose Division; 2. On or about January 19, 2010, Plaintiff and Defendants participated in an ADR phone

conference and agreed to participate in an early neutral evaluation ("ENE");
STIPULATION TO CONTINUE TIME TO COMPLETE ENE

C09-03330-RS
SV 346,658,808v2

Dockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 // //

3.

On or about July 22, 2010, the Court held a Case Management Conference setting the

case for ENE to be completed within 90 days, or October 20, 2010; 4. On or about September 7, 2010, Plaintiff's counsel moved to withdraw as attorney for

Plaintiff and a hearing was set for October 14, 2010; 5. On or about September 14, 2010, Walter J. Robinson was assigned by the Court as the

Early Neutral Evaluator; 6. On September 24, 2010, this court entered its Order extending the ENE deadline from

October 20, 2010 to December 6, 2010; 7. withdraw; 8. On February 15, 2011, William J. Goines of Greenberg Traurig, LLP entered an On October 6, 2010, this court entered its Order granting leave of Plaintiff's counsel to

appearance as counsel for Plaintiff; 9. On February 24, 2011, counsel for the parties met and conferred about the merits of

the case, scheduling, and related procedural issues; 10. On March 4, 2011, counsel for the parties conducted a conference call with the

assigned Early Neutral Evaluator, Walter J. Robinson, resulting in an agreed ENE date of April 26, 2011, with briefing schedules also duly established. IT IS HEREBY STIPULATED by and between the parties to the above-entitled action, through their respective counsel, that the deadline to complete ENE shall be extended from December 6, 2010 to April 29, 2011.

Dated: March 7, 2011.

Respectfully submitted, GREENBERG TRAURIG, LLP By: /s/ William J. Goines William J. Goines Attorney for Plaintiff and Counter Defendant MSGI Security Solutions, Inc.

-2 SV 346,658,808v2

STIPULATION TO CONTINUE TIME TO COMPLETE ENE

DOC TITLE LINE 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
-3 SV 346,658,808v2 STIPULATION TO CONTINUE TIME TO COMPLETE ENE

Dated: March 7, 2011.

LAW OFFICES OF DENNIS D. BROWN By: /s/ Dennis D. Brown Dennis D. Brown Attorney for Defendants

ATTESTATION CLAUSE I, William J. Goines, am the ECF User whose ID and password are being used to file this STIPULATION TO EXTEND TIME TO COMPLETE EARLY NEUTRAL EVALUATION AND [PROPOSED] ORDER. In compliance with General Order 45, X.B., I hereby attest that Dennis D. Brown has concurred in this filing.

Date: March 7, 2011.

GREENBERG TRAURIG LLP

By: /s/ William J. Goines William J. Goines

DOC TITLE LINE 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

[PROPOSED] ORDER

GOOD CAUSE APPEARING, IT IS SO ORDERED. Dated: 3/7/11 .

Hon. Richard Seeborg Judge, United States District Court

-4 SV 346,658,808v2

STIPULATION TO CONTINUE TIME TO COMPLETE ENE

DOC TITLE LINE 2